G.R. No. 144665 ; September 8, 2004
GAU SHENG PHILS., INC. and BESTOW OCEAN UNIA TRADING PTE. LTD., petitioners, vs. ESTELLA JOAQUIN, respondent.

FACTS

Roberto L. Joaquin was hired by foreign principal Bestow Ocean Unia Trading Pte. Ltd. through its local agent, Gau Sheng Philippines, Inc., to work as a fisherman. After 28 days at sea, he fell ill and was repatriated. His requests for medical assistance from the petitioners were denied. Roberto’s condition deteriorated, and he died eight months after repatriation due to chronic renal failure. His widow, Estella Joaquin, filed a claim for death benefits before the POEA.
The Labor Arbiter ruled in favor of the respondent, awarding death benefits and holding the petitioners solidarily liable. The NLRC reversed this decision, dismissing the complaint. The NLRC emphasized the seafarer’s failure to submit to a mandatory post-medical examination by a company-designated physician and the lack of proof that the illness was contracted during the employment term. The respondent then filed a petition for certiorari with the Court of Appeals.

ISSUE

Whether the death of seafarer Roberto L. Joaquin is compensable under the POEA Standard Employment Contract.

RULING

Yes, the death is compensable. The Supreme Court affirmed the Court of Appeals’ decision, which reinstated the Labor Arbiter’s award with modifications. The legal logic centers on the presumption of compensability and the nature of the employment contract for seafarers. The Court ruled that for an illness to be compensable, it is not necessary to prove that the risk of contracting the disease was increased by the working conditions. It is sufficient that the illness occurred during the term of the employment contract. Since Roberto fell ill just 28 days into his contract and was repatriated due to that illness, a reasonable causal connection between his work and his death is established.
The Court rejected the petitioners’ argument that the seafarer’s failure to report for a post-medical examination forfeited his claim. This requirement is not an absolute precondition for compensation, especially when the seafarer was incapacitated and the employer had already denied assistance. The clean bill of health issued prior to deployment strengthens the presumption that the illness was work-related. Furthermore, the principle of social justice underpins the interpretation of labor contracts, favoring the protection of seafarers. Consequently, the foreign principal and the local manning agency were held solidarily liable for the death benefits, funeral benefits, and accrued wages as stipulated in the applicable POEA memorandum circular.